"DC/CB combo. Both plans are top heavy, separately and combined as well. CB is hard frozen i.e. no one gets an accrual. There are quite a few participants excluded from the CB plan categorically. DC document says, top heavy is satisfied by DC plan but no % is provided. In addition to the 3% NESH already being provided under the DC plan, do I need it to provide another 2% PS allocation at all, especially for the participants who are excluded from participating in the CB? The only allocation to the key employees is the 3% NESH. There is no gateway requirement."

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"For those TPA firms that only use the services of an enrolled actuary for doing the actuarial valuation, SB and PBGC if required, but your firm is responsible for the compliance testing, what software do you use? Is there any standalone testing software that you have found to work, or do you primarily do the testing in some variations of Excel?"

"We have an LLC that is taxed as an S-corp. The owner only has one employee, her mother. Based on several discussions, I thought they would file an EZ. However, our actuary disagrees and based on 29 CFR § 2510.3-3 says that it is should be an SF. The 2025 Form 5500 filed for the 401(k) plan by a big box TPA filed as SF. What say you? Does it matter that it's an LLC taxed as an S-corp -- does it actually have to be an SF corp?"

"Does anyone have a good write up on how to perform 401(a)(26) prior benefit structure testing and how to perform it especially with some examples? Doing some research getting some conflicting information. Basically, have a hard frozen plan in 2025 (early in 2025 so no accrual) but the plan is overfunded so subject to 401(a)(26) -- this is confirmed. Also, terminated the same plan in mid-2026 and again need to test it for 401(a)(26). From what I understand, I can pick the termination date of 7/31/2026 as spot check date for 401(a)(26), correct?"

"CB plan -- PBGC covered, top heavy and NOT underfunded. My system does not to prior benefit structure testing so need to do all manually (confirmed with the vendor). Plan effective 1/1/2021 and combined with a DC plan. Plan is hard frozen early 2025 with no one accruing a benefit (except one owner getting AE increase as past NRA). I do not see any relief under SECURE 2.0 for this. I did the prior benefit structure testing and failed by 1 so need to 11-g. The confusion (or not understanding) I am having is that the 11-g is for a current year increase so how do I include this person into a testing that is performed at beginning of year? This person will have 1 additional year of accrual/participation versus others."